Legal Opinion

Du Pont v. Commissioner

United States Tax Court

Decided September 26, 1952No. Docket No. 17261Published

1. On the date of his death, Richard C. du Pont owned five single premium life insurance policies which he had taken out on his father's life. Decedent also owned a one-fifth undivided interest in a trust, the sole assets of which consisted of 17 life insurance policies on the life of his father. The father survived the decedent.

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1. On the date of his death, Richard C. du Pont owned five single premium life insurance policies which he had taken out on his father's life. Decedent also owned a one-fifth undivided interest in a trust, the sole assets of which consisted of 17 life insurance policies on the life of his father. The father survived the decedent. Held: For estate tax purposes, the proper measure of value of such policies, to the extent of decedent's interest therein at the date of his death, is the replacement cost thereof or, in the absence of such replacement cost, the respective interpolated terminal…

1Opinion of the Court

Estate of Richard C. du Pont, Deceased, Wilmington Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Du Pont v. Commissioner

Docket No. 17261

United States Tax Court

18 T.C. 1134; 1952 U.S. Tax Ct. LEXIS 90;

September 26, 1952, Promulgated

Decision will be entered under Rule 50.

1. On the date of his death, Richard C. du Pont owned five single premium life insurance policies which he had taken out on his father's life. Decedent also owned a one-fifth undivided interest in a trust, the sole assets of which consisted of 17 life insurance policies on the life of his…

2Cases cited10 opinions

  1. United States v. RyersonSupreme Court of the United States · 1941
  2. Guggenheim v. RasquinSupreme Court of the United States · 1941
  3. Powers v. CommissionerSupreme Court of the United States · 1941
  4. Welliver v. CommissionerUnited States Tax Court · 1947
  5. Wilmington Trust Co. v. Mutual Life Ins. Co.District Court, D. Delaware · 1948

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